Instructions for Continued Airworthiness (ICA) was not even a concept when any plane I’ve owned or flown was FAA certified. They do get applied to newly installed STC’d modifications but are not a factor for any modification I’ve made: basically they are required as part of package submitted by the modern day STC applicant, who then struggles to imagine what they might be and creates something trivial.
What can more commonly dictate maintenance procedures and periods is an item in the Airworthiness Limitations Section of the maintenance manual, for instance Cirrus parachute service. Again there is nothing of any consequence here in any plane I’ve owned or will likely ever choose to own, so my maintenance is on condition excepting for applicable AD compliance, for instance an AD requiring visual inspection of my engine mount at 100 hr intervals. Otherwise no plan, no mandatory items or periods and no paperwork except maintenance logbook entries.
So then, same as us.
Otherwise no plan, no mandatory items or periods.
Really? How do you get around the annual?
An annual inspection is not maintenance.
Peter wrote:
In theory, but most European pilots can’t use that, for reasons already posted.
Pilots have a Flight Crew Licence, not an Airworthiness Review Certificate. So no pilot can use a freelance PArt-66 for revalidation.
PetitCessnaVoyageur wrote:
I’m lost.
Renting an airplane to pilots is not CAT, but all the question was to know if it was commercial.
I’m surprised you affirm it is NCO.
To give you a definitive Answer that you can rely on, @PetitCessnaVoyageur, we’ll take a peek into the regulation. Also, forget what Peter is saying. All of it.
As has been stated, definitions for continuing airworthiness must not automatically follow operation. There are two distinctions to make when you look at operational requirements for the definition of airwothiness regime:
1) Is Part ML applicable in the first place?
As I have already explained to Peter, Part ML is always applicable when you do not fly commercially and the aircraft is not listed on an AOC. And that is the determining question: Is the aircraft listed on an AOC? If yes → Part-M applies. If not → Part ML applies. Very straightforward and unambiguous. The source is the cover regulation to continuing airworthiness (2019/1383), especially Article 3:
Article 3 Continuing airworthiness requirements
Regulation (EU) 2019/1383
2. The requirements of Annex Vb (Part-ML) shall apply to the following other than complex motor-powered aircraft:
(a) aeroplanes of 2 730 kg maximum take-off mass or less;
(b) rotorcraft of 1 200 kg maximum take-off mass or less, certified for a maximum of up to 4 occupants;
(c) other ELA2 aircraft.
Where aircraft referred to points (a), (b) and (c) of the first subparagraph is listed in the air operator certificate of an air carrier licensed in accordance with Regulation (EC) No 1008/2008, the requirements of Annex I (Part-M) shall apply.
(accentuation by me).
The second question is, if the aircraft is flying for a commercial ATO/DTO for other purposes than training the owner(s) of the aircraft? If this is the case, you need a CAO/CAMO to manage (and take responsibility for) the airworthiness of the aircraft. Also, all work must be performed by a CAO or PArt-145. No freelance mechanics allowed for commercial ATO/DTO. The source is ML.A.201 Responsibilities:
(e) For aircraft operated by commercial Approved Training Organisations (‘ATO’) and commercial Declared Training Organisations (‘DTO’) referred to in Article 10a of Regulation (EU) No 1178/2011 or not operated in accordance with Annex VII to Regulation (EU) No 965/2012 (Part-NCO) or operated in accordance with Subpart-ADD of Annex II (Part-BOP) to Regulation (EU) 2018/395 or Subpart-DEC of Annex II (Part-SAO) to Regulation (EU) 2018/197633, the operator shall:
(1) be approved as a CAMO or as a CAO for the management of the continuing airworthiness of its aircraft in accordance with Annex Vc (Part-CAMO), Subpart G of Annex I (Part-M) or Annex Vd (Part-CAO), or contract such an organisation using the contract set out in Appendix I to this Annex;
(2) ensure that all maintenance is performed by maintenance organisations approved in accordance with point (c)(2) of point ML.1.;
(3) ensure that the requirements of point (a) are satisfied.
GM1 ML.1.201 gives an overview:
The question, what exactly defines a commercial ATO or DTO is explained in GM1 ML.A.201(e):
COMMERCIAL ATO/DTO
According to industry practice, the following are examples of aircraft not considered to be operated by a commercial ATO or a commercial DTO:
(a) Aircraft operated by an organisation holding an ATO certificate or a DTO declaration, created with the aim of promoting aerial sport or leisure aviation, on the conditions that:
(1) the aircraft is operated by the organisation on the basis of ownership or dry lease;
(2) the ATO/DTO is a non-profit organisation; and
(3) whenever non-members of the organisation are involved, such flights represent only a marginal activity of the organisation.
(b) Aircraft operated under Part-NCO by its owner together with an ATO or a DTO flight instructor for the purpose of training, when the contract between the owner and the training organisation and the procedures of the training organisation allow it. The continuing airworthiness of such aircraft remains under the responsibility of the owner, or of the CAMO or CAO contracted by the owner, if the owner has elected to contract a CAMO or CAO in accordance with ML.A.201(f).
(c) Aircraft used for very limited training flights due to the specific configuration of the aircraft and limited need for such flights.
If you have further questions on this (topic), I impertinently recommend one of my workshops with AOPA. The first AOPA English workshop will be held on June 12th via ZOOM: https://aopa.de/event/online-seminar-introduction-to-european-aircraft-maintenance-for-pilots-and-owners-on-june-12th-2021/
Also, forget what Peter is saying. All of it.
That’s nice of you, MH. Others will judge you from your manner. Nothing new, but one is never too old to learn.
I have already commented sufficiently on how easily quoting paragraphs from Part-ML can be heavily disingenuous, due to maintenance industry politics, etc. As someone who makes a living from the EASA regulatory system you should be a little more generous towards those who work for free while providing you with a platform on which to promote your commercial activities. Maybe, facebook would be better for that; almost everybody there is pumping some business, or a YT video subscription number… Try it; you might feel right at home.
I am hopeful that post-EASA the UK system might gradually dismantle the CAMO structure.
There is a certain amount of disingenuity in saying “you don’t have to use a CAMO” because for many people, depending on location, there is no other practical choice. Using a freelancer doesn’t work because of protectionist rules (no maintenance allowed in hangar) and many maintence companies only want your business if working as a CAMO. Many maintenance companies rule themselves out through not wanting the business, not being prepared to discuss anything, not committing to timelines and keeping you grounded for a month, etc.Certainly in the UK certified scene – which until very recently was EASA – most people are stuck with some circumstance-specific arrangement that is tolerable to a greater or lesser degree and have little realistic opportunity to try different firms or different maintenance arrangements. In our TB10 group we are lucky that our CAMO is excellent, but the downside they are the other side of London. If we couldn’t use them I don’t know what we’d do.
I like the LAA permit system. Annual inspection (not annual service) by an individual licenced by the LAA and the rest is up to you. Similar to the FAA philosophy?
This stuff about “how do you trust someone without a regulatory structure overseeing their work” baffles me. I decide who I trust to work on things based on my assessment of their knowledge, skills and (more importantly) their attitude. It would never occur to me to rely on a government-appointed regulator to do this for me, and nor would I ever trust such a system ahead of my own judgement.
There is a certain amount of disingenuity in saying “you don’t have to use a CAMO” because for many people, depending on location, there is no other practical choice.
The same is true for saying „many people“ must use CAMO, 145 etc… it’s misleading.
This seems to be a UK phenomenon. Austria has a much smaller GA market than the UK, and still there a plenty of shops that will happily maintain a plane to the owners wishes / declared AMP. Without a CAMO!
So before EASA Part-ML, could a G-reg owner maintain the prop on condition?
I have no idea.
On the TB the CAMO looks after the CS prop, – they are a specialist prop shop with an excellent reputation and I trust then.
On the Vagabond the prop is a lump of wood bolted to the end of the crankshaft. Beyond torquing the bolts I’m not sure how much maintenance one can really do on it, so yes it is ‘on condition’, if you like.
there a plenty of shops that will happily maintain a plane to the owners wishes / declared AMP.
@Snoopy that is also possible in the UK, and the private owner can then use the Maintenance Manual as the model, and yes, the owner can elect to keep components on condition.
The Piper MM is easily transferred to an owner declared AMP.
My understanding is before Part-ML the UK didn’t allow Props on condition.
